Gazprom PJSC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Gazprom discloses climate-policy lobbying in extensive, specific detail. It names multiple concrete legislative or regulatory initiatives it has tried to influence, including the draft Federal law “On state regulation of greenhouse gas emissions and on amendments to certain legislative acts of the Russian Federation,” work on the Federal law that would “ensure the preparation and submission of information… on the volume of GHG emissions,” its proposal to “exclude methane from the list of pollutants approved by the order of the Government of the Russian Federation dated July 8, 2015 № 1316-p,” and its role in developing sectoral BREFs for crude hydrocarbon production and processing. The company is equally explicit about how and where it engages: it “participated in a meeting of the Interdepartmental working group on economic aspects of environmental protection and regulation of greenhouse gas emissions” at the Ministry of Economic Development, “constantly cooperates with ministries and agencies” such as “the Russian Ministry of Natural Resources” and the “Technical Committee of the Federal Agency on Technical Regulating and Metrology,” submits formal proposals to Rospotrebnadzor, and provides annual emissions data to Roshydromet. Finally, Gazprom sets out clear policy outcomes it seeks, for example urging that targets be set “in the form of specific indicators aimed at reducing emissions per unit of production,” calling for regulatory updates that embed “best available techniques,” asking to drop methane from the national pollutant list on the grounds of “scientific evidence of methane’s non-toxicity,” and pressing for stronger economic incentives beyond the draft law’s “accelerated depreciation and tax incentives.” This level of specificity across policies, mechanisms, targets, and desired changes demonstrates a comprehensive degree of transparency in the company’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
None	Gazprom Energoholding Group provides a detailed account of its legislative engagement, noting that “experts of the Group companies are actively involved in discussions held on various platforms to ensure the Group’s interests are taken into account,” with its representatives “upheld the Group’s corporate interests” on amendments ranging from improving market mechanisms to “stimulating the development of renewable energy sources in the retail electricity market.” It also highlights collaboration with federal authorities through “participating in consensus meetings and working groups” and in drafting initiatives such as Federal Law No. 59-FZ and guidelines on heat-supply connection. However, we found no evidence of a dedicated policy or process specifying how lobbying activities are governed or aligned with climate objectives, and the company does not disclose a specific individual or committee that oversees such lobbying practices.	0